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3232114453222Objecting to Glyphosate Desiccationhttp://safefoodmatters.org/2017/10/30/objecting-to-glyphosate-desiccation/
http://safefoodmatters.org/2017/10/30/objecting-to-glyphosate-desiccation/#respondMon, 30 Oct 2017 15:30:52 +0000http://safefoodmatters.org/?p=203Glyphosate is being sprayed on crops to kill them for harvest, and the poison gets right into the still-growing seeds and beans: the food we eat. High and illegal levels in “healthy” foods like chickpeas result from this “desiccation” technique.

Health Canada just renewed the registration for glyphosate for another 15 years, and only tweaked the labels for spraying. It didn’t examine the effects of desiccation, and the tweaks won’t change desiccation exposure. Labels won’t work, aren’t followed, can’t be enforced, and Health Canada’s own law even admits it.

These points were made in a Notice of Objection (“NOO”) filed with Health Canada on June 27, 2017. The NOO was filed to object to Re-evaluation Decision RVD 2017-01 of the Pest Management Regulatory Agency (“PMRA”) to grant continued registration of glyphosate.[i] A summary of the NOO is below.

Residues exceed legal limits (eg. chickpeas)

Desiccation is occurring on a large scale in North America. The literature indicates when glyphosate is applied to crops that have already emerged, it moves preferentially to growing points, to where the sugars are, which are called “sinks”. In cereals and legumes the sink is the seed, and studies have found high levels of glyphosate in spring wheat, field pea, barley, flax, canola, dry beans and lentils, among other crops.

The scientific literature indicates that the early application of glyphosate as a desiccant or application when moisture content is too high has resulted in exceedances of the Maximum Residue Limits (“MRLs”) for some crops: in Canada and/or countries that import the particular crop. Studies have shown this with respect to wheat seed, red lentils, dry beans and field peas, at a minimum.

In Canada, chickpeas are of particular concern. The Canadian Food Inspection Agency (“CFIA”) sampled foods for glyphosate in 2015-16, and chickpeas exceeded the MRL in more than a third of the samples. The data was recently obtained pursuant to an Access to Information Request submitted by Mr. Tony Mitra, and it indicated “violations” had occurred with respect to twenty-six out of 71 chickpea samples assessed, or 36.6%.

“Food containing a pesticide residue that does not exceed the established MRL does not pose a health risk concern”, according to PMRA in RVD 2017-01. Based on PMRAs own criteria, desiccated chickpeas are a health concern.

Exposure in diet not examined

There is no discussion of dietary exposure through harvest management or desiccation applications of glyphosate in the content of RVD 2017-01, or its predecessor document that set out the evaluations conducted, PRVD 2015-01.

Consumption levels show huge increase

Exposure to a pesticide is determined by combining the amount of pesticide that is in or on the food (residue levels) and the amount and type of food that people eat. But the data on the amount of food consumed is incredibly outdated. PRVD 2015-01 adopts Science Policy Note SPN 2003-02, which points to food survey data from at best 1998 from the Canadian Survey of Food Intake II (CSFII). Even if more current data available to PMRA is taken into consideration (based on the fact Science Policy Note SPN2014-01 indicates PMRA was adopting the United States WWEIA (What we Eat in America)), this data goes back to 2010 at best.

Such outdated data can’t provide an accurate evaluation of current dietary exposure. The consumption of chickpeas in the United States has grown at least 90% since 2010. Hummus is a dip made form chickpeas, and over a quarter of Americans reported in 2014 that they had the dip in the refrigerators. Consumer spending on hummus reached $1 billion a year in 2014, after growing some 18% a year over the previous five years – six times faster than the overall growth of the American food market. Lentils and other leguminous crops have also trended high for several years, and lentils and chickpeas will reach record highs in the 2016/17 marketing year.

Because consumption is increasing, production is as well. The production in the United States of dry beans (including chickpeas) and lentils increased from less than 3 billion pounds in the 2011/12 production year to approaching 6 billion pounds in the 2016/17 production year. Statistics Canada numbers on the domestic use of “Pulse and Special Crops” indicate an increase from 769,000 metric tonnes in 2010-11 to a projected 1,914,000 metric tonnes in 2016-17, an increase of 250%.

MRLs for unregistered products not valid

Glyphosate has to be registered for use as a desiccant in Canada. There are two ways registration can occur: one is if the chemical company actually does the registration, and the second is under a program called “URMULE”: User Requested Minor Use Label Expansion, where an “applicant” does the registration.

The Minister of Health sets the MRLs under URMULE, and in so doing under law he or she must evaluate only the health risks of the product, and he or she must consider these to be acceptable.

Chickpeas are registered under the URMULE program for the use “Crop Staging for Preharvest Applications”. At a minimum, the following crops have also been so registered under the URMULE program: canary seed, mustard, lupin and faba bean.

It appears from the RVD 2017-01 that MRLs for the use of glyphosate as a desiccant on conventional (non-URMULE) crops were established based on field trial studies, but there is no indication in either RVD 2017-01 or PRVD 2015-02 that URMULE crops have been examined for such use, nor is there evidence that, in any such examination, only health risks were evaluated. The historical evidence is that the limit is set based upon the amounts of residues in fact found in the proponents’ studies, not based on health considerations. So it appears the legal requirements for setting MRLs for URMULE crops have not been followed.

Label Amendments don’t address the risk

The result of the Re-evaluation was that PMRA required changes to labels about spray buffer zones for glyphosate. The risk from eating glyphosate contained in desiccated crops is not mitigated by such changes, because the crop is located right in the spray zone.

The risk would still exist even if labels required spraying when moisture content is low, especially with indeterminate crops such as pulses, canola and flax. These plants continually produce flowers as the plant grows, resulting in mature pods at the bottom and greener, more wet, material at the top, so there will always be wet material containing higher glyphosate levels in the plants. Also moisture content is determined not only by physiological maturity of the plant, but also by the weather, and the weather cannot be controlled or predicted. Studies indicate if a crop is desiccated and then after that heavy rains occur, the moisture content can be affected. Also, the determination of moisture content by visual indicators is a subjective determination, and so subject to error. Moreover, even if visual indicators do provide accurate determinations, they are at best guidance and not prescriptions that can be enforced.

Labels aren’t followed anyway

The successful implementation of any label amendment is based on the assumption that labels will be followed. The problem is that labels are not in fact followed in Canada; a fact that has been reported by PMRA.

One example is from the Pest Management Regulatory Agency/ Regulatory Operations and Regions Branch. The Compliance and Enforcement Report for 2015-2016 indicated that most of the instances of non-compliance for that year were of three types, including “use contrary to the label approved by PMRA”.

Enforcement won’t work

The Compliance Policy followed by PMRA is unlikely to lead to label enforcement. The only applicable inspection tool for the PMRA is “monitoring inspections”. Because the seeds on even one plant have different maturity levels depending on their stage of growth, the inspector would need to examine the crop at the exact time the determination is made, and this would be administratively and practically difficult. He or she would also need to ensure that the moisture content is not increased after desiccation because of rain. Moreover, because the determination of moisture content is a subjective judgement, there is no clear line for when moisture content is appropriate. Enforcement without clear lines is administratively and legally difficult.

Health Canada’s own law admits labels don’t stop exceedances

It is hard for Health Canada to argue that label amendments will solve the glyphosate problem when the federal government already has a law on its books that admits MRLs are exceeded even when the label is followed.

The Pesticide Residue Compensation Act provides compensation for any loss suffered by a farmer as a result of the presence of pesticide in or on an agricultural product of that farmer, if (a) an inspection disclosed the presence of a residue that would render a sale contrary to the Food and Drugs Act (i.e. the MRL would be too high); (b) the pesticide is nevertheless registered or deemed registered under the Pest Control Products Act: (c) the pesticide was used in accordance with practices approved, recommended, directed or concurred in by the Minister of Health (i.e. in accordance with label directions); and (d) the Minister is satisfied that the presence of the pesticide is not the fault of the farmer, his employees, agents etc. or those of the previous owner.

Thus this compensation act contemplates that MRLs will be exceeded even when label directions are followed.

Request

When timely notice of a Notice of Objection is received, the Minister of Health can establish a review panel to review the decision (pursuant to Section 35 of the Pest Control Products Act). The Minister must either give public notice of the establishment of the panel or provide written reasons without delay to the objector. The above objections warrant the prompt establishment of a review panel.

[i]This decision was based on a re-evaluation set out in PVRD 2015-01, which looked at “available scientific information” but did not ask for any new information to be supplied by the registrant beyond that provided in the initial evaluation. Glyphosate was first registered in Canada in 1976, and the registration on record of glyphosate for pre-harvest use is based on Agriculture Canada’s Decision Document E92-02 (June 15, 1992) Pre-Harvest Use of Glyphosate.

]]>http://safefoodmatters.org/2017/10/30/objecting-to-glyphosate-desiccation/feed/0203Glyphosate in our Food II: Highest Levels in Legumes & Cereals because of Farming “Dry-Down”http://safefoodmatters.org/2017/09/14/glyphosate-in-our-food-ii-highest-levels-in-legumes-cereals-because-of-farming-dry-down/
Thu, 14 Sep 2017 18:03:13 +0000http://safefoodmatters.org/?p=158For those concerned about pesticides in our foods, the link between harvesting practices and staggering high levels of glyphosate in common “healthy” cereals and legumes may come as a shock. Glyphosate, the active chemical in Roundup® and other pesticides, is considered to be “probably carcinogenic to humans”[i], a cause of non-hodgkins lymphoma, toxic to aquatic life,[ii] and a cause of milkweed decline.[iii]

High levels of glyphosate are present in many common foods, but so high in cereals and legumes that Canada’s legal limits are exceeded, as revealed by data from the Canadian Food Inspection Agency (CFIA) and other data[iv]. The CFIA data[v] revealed violations of Canada’s maximum residue limits in 26 out of 71 samples of chickpeas sampled (36.6%), and 2 out of 55 wheat bran samples. There were also violations for kidney bean, rye grain and products, bean flour, chickpea products and flour, and millet. Glyphosate was detected in 36.6% of grain products, 47.4% of bean/pea/lentil products, and 31.7% and 30.7% of infant cereal and food, respectively.[vi]

It appears these high levels result from a farming technique called “desiccation” or “drying down”, intended for crops that ripen unevenly or contain green material. The chemical is sprayed right on to the crops, while they are still growing in the field, in order to deliberately kill them at a targeted time and allow for a planned harvest. Glyphosate, a “systemic” chemical, gets rights into the circulation system of the plant and moves to the points of sugar delivery. These points are called “sinks”; they are typically roots, young shoots and developing seeds. For cereals and legumes, the “sinks” are the developing seeds, which is what we eat.

There is no way to know what specific crops have been desiccated with glyphosate, because farming techniques are not monitored.[vii] There is also no way to know when the crops are sprayed. Timing is important: authorities say that if spraying occurs when there is more than 30% moisture content in the crop, then more glyphosate ends up in the seed sink. The practise guideline for determining the “stage of growth” is a “thumbnail test” and “visual colour test”[viii]. These guidelines are problematic, especially with indeterminate crops like beans that don’t stop producing seeds, because their seeds don’t mature all at the same time.

Safe Food Matters recently objected to the 2017 re-registration of glyphosate in Canada on the basis of this desiccation issue, among other things. Glyphosate has been in commercial use in Canada since 1994, and was re-registered in 2017, following a re-evaluation process that is required by law[ix] every 15 years. The most recent process started in 2009 and took 8 years. A summary of the arguments set out in the Notice of Objection can be viewed here.
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[i] World Health Organization, International Agency for Research on Cancer. (March 2, 2015). IARC Monographs Volume 112: evaluation of five organophosphate insecticides and herbicides at 1 online https://www.iarc.fr/en/media-centre/iarcnews/pdf/MonographVolume112.pdf [ii] Canadian Association of Physicians for the Environment and Equiterre, “Backgrounder: Glyphosate: Ubiquitous and Worrisome” (2017), online https://cape.ca/wp-content/uploads/2016/05/Glyphosate-Bckgd-ENG-2016.pdf[iii] Zaya, D. N., Pearse, I. S., & Spyreas, G, “Long-term trends in Midwestern milkweed abundances and their relevance to monarch butterfly declines” (2017) 67(4) Bioscience 343-356[iv] Academic studies report glyphosate concentrations in wheat seed, red lentils, dry beans and field peas that exceed the legal limits of Canada or other countries. Studies also report high levels in spring wheat, barley, flax, canola, and lentils.[v] As reported by Tony Mitra in “Glyphosate in chickpea, lentil and wheat bran” (June 15, 2017), online http://www.tonu.org/2017/06/15/glyphosate-in-chickpea-lentil-and-wheat-bran/[vi] Canadian Food Inspection Agency. (2017) Safeguarding with Science: Glyphosate Testing in 2015-2016 at 4 online at http://www.inspection.gc.ca/DAM/DAM-food-aliments/STAGING/text-texte/chem_testing_report_2015-2016_glyphosate_srvy_rprt_1491855525292_eng.pdf[vii] In Canada, companies have registered glyphosate for use as a desiccant on wheat, barley, oats, canola, flax, lentils, peas, drybeans and soybeans. The Pest Management Regulatory Agency has also permitted it to be used on the additional crops of chickpeas, lupin, faba bean, canaryseed, camelina, mustard and forage[vii], even though no company has registered it for such use. (Saskatchewan Ministry of Agriculture. (2017). 2017 Guide to Crop Protection at 235). Such use is permitted under the User Requested Minor Use Label Expansion program.[viii] Monsanto Company, Roundup Preharvest Staging Guide, 4 online at http://www.roundup.ca/_uploads/documents/MON-Preharvest Staging Guide.pdf[ix]Pest Control Products Act, S.C.2002, c.28 sec 16(1).

]]>158GLYPHOSATE IN OUR FOODhttp://safefoodmatters.org/2017/02/25/glyphosate-in-our-food/
http://safefoodmatters.org/2017/02/25/glyphosate-in-our-food/#respondSat, 25 Feb 2017 23:21:47 +0000http://safefoodmatters.org/?p=143There is glyphosate in our food, including infant cereal. Glyphosate is the most widely used herbicide in the world.

Tony Mitra, a retired engineer living in Vancouver, asked the CFIA for test data on glyphosate, and they provided it this year. The CFIA (Canadian Food Inspection Agency) has been testing the food in Canada for only about 2 years.

Mr. Mitra has found (so far):

Infant cereals are contaminated, except for Nature’s Path Organic and imports from Germany, Poland and Switzerland.

Wheat and its products are contaminated. Bran is extremely high on a relative basis. Organic is better in all wheat cases.

Rice is not bad, especially from India and Thailand. No mention so far of organic.

Legumes from the US and Canada are contaminated, especially garbanzos/ chickpeas. No mention so far of organic. Chinese imports appear to not contain glyphosate.

Fruits and vegetables are generally without glyphosate (preliminary review).

General principles emerging are:

if it is a grain or legume grown by conventional methods in Canada or the US, the more likely the contamination; and

the more processed, the more likely the contamination.

Glyphosate is used in conventional farming in North America to: (1) kill weeds; and (2) make growing crops (like chickpeas and wheat) “dry-down” (desiccate) for harvest. When used as a desiccant, it can get right into the seed.

Mr. Mitra is still working on this project, and indicates the results are not complete. He is periodically posting his findings and providing backup on his blog at www.tonu.org. He intends to complete his analysis and publish an e-book in the Spring.

Health Canada in May, 2016 approved a genetically modified animal (salmon) for human consumption. This food is the first of its kind in the world. A federal committee that looked at the issue has provided its report, which effectively includes a recommendation to not label GM foods.

The Standing Committee on Agriculture and Ari-Food stated it supports mandatory labelling “only when a risk to health has been established …”, and that “no risks to health have been identified for GM foods approved in Canada”. (7,8)

But of course no health risks can be identified, because GM ingredients can’t be traced. Why not? Because they aren’t labelled. Bit of a Catch 22, eh?

The Pickle.

Canadians want labelling of GM foods. Health Canada in March, 2016 commissioned research to “obtain a more current reading on public opinion”. The findings (at 5) were that 78% of participants want GM foods clearly labelled on packaging, and that “consumers are simply not convinced that GM foods are as safe or safer… relative to comparable non-GM foods”.

Yet Health Canada and the CFIA assured the Committee in its report that “GMOs currently on the market are safe both for human and animal health and for the environment”. Their argument has been heard before: “[T]hat there is no evidence of harmful effects after almost 20 years of GMO use for animal feed and for human consumption”. (at 7)

But of course evidence of harmful effects can’t be found, because GM ingredients are not traceable; again because they are not labelled. Plus the 20 year argument doesn’t work, because Health Canada’s mandate is to ensure it has been established that GM foods are safe (Food and Drug Regulations B.28.002(1)), not wait around to see if harmful effects show up.

They also say they “examine the data provided by the industry according to the protocols of international standards, [and] they also consider the current scientific literature” (at 7). Fair enough, but this isn’t good enough to establish safety. The data, if any, is provided by the companies, and the standard tests are only 90 days (problems arise after two years generally). Plus no current scientific literature establishes that GM foods are safe.

It would seem the regulators are in a bit of a pickle on the safety issue. The basis for establishing safety may not be that firm. If they promote mandatory labelling of GM foods, they are admitting that the foods may not be safe, and then Canadians would ask “Well what have you been doing approving these foods?” Especially since Canadians want them labelled.

How to Avoid It.

But there be may be another approach. Under the Food and Drugs Act, all ingredients and components of food must be labelled. There is also a requirement (section 5.1) to label food in a way that is not “misleading or deceptive or is likely to create an erroneous impression regarding its character, value, quantity, composition, merit or safety”. The CFIA explains that “It is unacceptable to use partial truths, as these are likely to create a false impression. This includes the failure to disclose the essential facts about the properties or composition of a food…”

Let’s take the GM salmon. It is the first and only food of its kind in the world. It differs from “normal” salmon in at least 3 other ways. It contains the genes of an eel-like animal, higher levels of the growth hormone IGF-1 (which is tied to several common cancers), and statistically significant (1.5 times) higher levels of allergen content (see To the Salmon Consumer: I’m not Buying It). Given these points, to not label GM salmon would likely create an erroneous impression regarding its “character, value, composition and merit”. It would also constitute a failure to disclose essential facts about the properties or composition of food.

The regulators could hang their hats on the Food and Drugs Act and satisfy Canadians’ desire for labelling GM foods without getting into the pickle on safety.

]]>http://safefoodmatters.org/2016/12/16/labelling-gm-salmon-and-foods/feed/0128SynBio, Gene Editing and Other New Stuff: Same Concerns, Supersized.http://safefoodmatters.org/2016/11/01/synbio-gene-editing-and-other-new-stuff-same-concerns-supersized/
http://safefoodmatters.org/2016/11/01/synbio-gene-editing-and-other-new-stuff-same-concerns-supersized/#respondTue, 01 Nov 2016 21:20:11 +0000http://safefoodmatters.org/?p=107New words like “synthetic biology”, “GMOs 2.0”, “CRISPR”, and “new biology” are being heard. And new compounds are in our fragrances, flavourings, cosmetics and foods.

The new words are for new techniques of genetic engineering. What are the techniques and their products, and should we be concerned?

New Techniques­

The old techniques of genetic engineering (GMOs 1.0) dealt with organisms, and inserted genes by either blasting them into an organism or transferring them via a virus. This was not very precise.

1. Gene Editing. A new technique is called “gene editing”. It is more on target. It can cut the genetic code of organisms with greater precision, insert new code, remove a code and swap out genes with others. Tools used in gene editing include “CRISPR-Cas9”, “Zinc Finger Nucleus” and “TALEN”.

2. Synthetic Biology. Another new technique is the creation of genetic code from scratch, without involving living organisms. This is called “synthetic biology” or “put together life”. It uses computer design technology to engineer and produce new codes in the lab.

Applications and Technologies

These techniques, when applied, have resulted in far-reaching technologies.

a) Applications of Gene Editing

Gene Drives. A much talked-about technology is “gene drives”. It drives the particular gene down to the offspring and doesn’t allow space for an alternate to arise, as would occur in natural evolution. Once a trait is forced down at the expense of the alternatives, the extinction of the “alternate” offspring is the ultimate result.

Gene drives have so far been used on yeast, fruit flies and 2 mosquito species, but have not yet been released to ecosystems. There is widespread discussion about using them to eradicate mice on islands, mosquitoes, and pests.

GMOs 2.0. Gene editing is also used in agriculture, the old domain of GMOs 1.0. With GMOs 2.0, food is being engineered to insert, delete or replace DNA, and entirely new sequences are being created. Gene edited mushrooms (deletions in a gene for non-browning) and canola oil (a gene removed to tolerate herbicide) have both been commercialized. Monsanto in September, 2016 licensed the use of CRISPR to engineer food and Dupont in October 2015 predicted that CRISPR plants would be on dinner plates within 5 years. Proponents of gene editing argue that the resulting organisms are not “GM” or “novel substances”, and therefore aren’t subject to current regulation.

b) Applications of SynBio

Foods, Flavours, Fragrances. The synbio technique has spawned many new applications, including the creation of new compounds in consumer products that are so similar to existing products consumers can’t tell the difference. The method used is to engineer artificial code into microbes and then ferment them on a large scale in vats. Manufacturers use the word “natural” because fermentation is involved.

New Life Forms. Another application is the engineering of completely new genetic codes and life forms. Current players in this sphere include the “DIY” community, students, and start-ups. A code can be created on the computer and 3-D printed. The International Genetically Engineered Machine Competition (IGEM) is a university and high school competition for building “biobricks” (like lego) to operate in living cells. A recent commercial example of a new life form is a plant that glows in the dark.

Bio Weapons. A third application is military. In the US, the Defense Advanced Research Projects Agency (DARPA) provides the most funding for synthetic biology in the US government (although the extent to which this is funnelled to bioweapons is not known). In the US, the Army, Navy and Office of the Secretary of State are also funding synbio. (See Extreme Genetic Engineering and the Human Future, p 31).

What is the Concern?

The concern is we don’t know if the new technologies are safe. Why not? Because we don’t completely understand the interactions that occur in living organisms and ecological systems.

Organisms are complex systems in which chemical reactions “fire” at different times and places along interconnected pathways. They do not behave in linear “cause and equal effect” ways, in either space or time. A gene is part of this system. It is a strand of DNA that messages or “fires” at times (or refrains from “firing”) and brings about an action or change in an organism. Similarly, ecological systems are complex systems. They rely on species interconnections and interactions which also don’t behave in linear “cause and equal effect” ways.

If a complex system does not behave in a linear fashion, the workings of the systems cannot be known ahead of time and its effects cannot be predicted. Similarly, the effects resulting from a change to one aspect of a system cannot be predicted. The effects can only be known “after the fact”, and, depending on the system, these effects may vary.

This inability to predict the results of a change in the system was the problem with GMOs 1.0, and is the same problem with these new techniques. The concern will exist every time one of the new techniques is used in a complex living system. The scientific literature even acknowledges that there are often “unintended” or “unpredicted effects” associated with the products of genetic manipulation. New substances are often created. Even CRISPR-Cas9 technology admittedly has the problem of being “off-target”.

Historical Examples

The concern of unpredictability is underlined by historical examples of GMOs 1.0 gone wrong. In the late 1990s and early 2000s several people died as a result of reactions to gene therapy procedures, the most notable of which was 18 year old Jesse Gelsinger. He died from a severe immune reaction to the viral vector used to transport engineered genes. Another example is the food supplement L-Tryptophan. Genetic modification of the supplement created a new toxin that is linked to EMS, a disease that killed 80 people and afflicted thousands in the late 1980s, early 1990s. (See “L-Tryptophan”).

Examples of agriculture GMOs 1.0 gone wrong include the case of canola. In 1995 Canada became the first country to approve commercialization of genetically engineered canola. GM canola has now spread and eliminated natural canola almost everywhere in Canada. Other examples of GM plants that have spread uncontrollably are: creeping bentgrass in the USA; cotton and maize in Mexico; BT poplar in China; Bt rice in China; and canola in Japan, the US, Australia and the EU. (See Transgene Escape by TestBiotech).

Supersized Concerns

The concern of unpredictability is more pronounced with these new synbio and gene editing techniques than with GMOs 1.0. Reason? The applications of these new techniques are very broad in scope, and their effects can be devastating.

Gene Drives. The scope of gene drives is obviously major. It extends to the possible extinction of a species, and resulting degradation of its ecosystem. Even the National Academy of Sciences of the US, in a June 2016 report (at 86), admits that: “[R]eleasing a gene-drive modified organism into the environment means that a complex molecular system will be introduced into complex ecological systems, potentially setting off a cascade of population dynamics and evolutionary processes that could have numerous reverberating effects”.

GMOs 2.0. The scope of GMOs 2.0 extends to the food humans and animals eat and to the environment. The lack of current regulation and the speed at which the products are being advanced means the GMO 2.0 technologies and products will likely be used before they are assessed. This is even though the effects with GMOs 2.0 are compounded. Testbiotech indicates that with the new gene editing techniques, a single step can be applied several times, causing large changes; plants and animals with genetic changes can be crossed with each other; different techniques can be used in combination with each other; and that even small steps, if repeated, enable radical changes in the genome.

Foods, Flavours, Fragrances. The scope of the synbio application is enormous, on many fronts. The flavours and fragrance market is advancing quickly: it was a US $26.5 billion market in 2016 and is expected to grow to over US $35 billion by 2019. Lux Research indicates synbio will be a “permanent and growing aspect” of the flavours market. A major socioeconomic effect is the displacement of natural botanical farmers: 95% of varieties of natural crops are grown by small-scale farmers, more than 20 million of whom depend on these crops for their livelihood.

The new compounds themselves are pervasive in our consumer products without being identified (except they might be called “natural”). Common names include: method, Ecover, patchouli, PeterThomasRoth, Evolva, Clearwood, TerraVia, Neossance Biossance, Eversweet (in Coca Cola Life), Agarwood Oil, Muufri animal free milk, among others. The effect of these compounds on human beings has not been subject to regulatory assessment, even though they are biologically different than the natural botanical substances.

New Life Forms. The synbio creation of new life forms in the DIY community is advancing, and there is no way to monitor the proliferation of this technology. The September 2016 report of Genome editing: an ethical review points out that a number of websites provide lab and other support services for amateurs, and DIY CRISPR kits are available on line. A code can be 3-D printed and Fedexed for less than $100. The seeds and kit for the new glowing plant can be ordered on-line. The potential for intentional and unintentional release obviously exists, again with no regulations in place.

BioWeapons. The scope of the military application of synbio is not known, but appears to be growing as increasing amounts of government funding are directed toward the technology. The obvious risks are the inability to recall a release, and the potential for a release to be off-target.

In Sum

New technologies are advancing quickly and new products and substances are in our world. Genes can now be created from scratch, a wide array of new products and foods can be created with greater precision, and whole species can be affected. The concerns around safety and unpredictability are the same, but the resulting risk profile has increased dramatically. We would do well to learn the new words.

]]>http://safefoodmatters.org/2016/11/01/synbio-gene-editing-and-other-new-stuff-same-concerns-supersized/feed/0107A BEEF ON LABELING: IRRADIATED MEAT GETS A LABEL; BUT GM FOODS DO NOThttp://safefoodmatters.org/2016/08/31/a-beef-on-labeling-irradiated-meat-gets-a-label-but-gm-foods-do-not/
http://safefoodmatters.org/2016/08/31/a-beef-on-labeling-irradiated-meat-gets-a-label-but-gm-foods-do-not/#respondWed, 31 Aug 2016 15:38:49 +0000http://safefoodmatters.org/?p=50Health Canada is going to allow the beef industry to irradiate beef: to blast it with radiation. But it insists that such beef be clearly labeled so that “consumers wishing to purchase irradiated ground beef would easily be able to identify it on store shelves.” [i]

However there is no requirement to label genetically modified foods. It is hard to understand why there is a requirement to label one but not the other, because they are similar in many respects. Here are the similarities:

Both Are Processes at the Molecular Level

Irradiation is a process, according to the Technical Summary[ii], that is applied to ground beef at the molecular level, the level of DNA. The Updated Evaluation[iii] of irradiated beef states (at 5) that “The mechanism of action for microbial inactivation using ionizing radiation is understood to involve breakage of the chemical bonds in the microbe’s DNA by free radicals, which arrests microbial growth (Black and Jaczynski 2006)”.

Genetic modification is also a process, and it is applied at the molecular level. The mechanism for action of genetic modification is understood to involve inserting genes into the DNA of an organism to create specific proteins to perform a function.

Both Are Evaluated by Health Canada

The products of irradiating beef and of genetically modifying foods both undergo an evaluation by Health Canada. On irradiation, Health Canada indicates “In Canada, all new uses of food radiation must undergo a thorough safety evaluation to ensure that the radiation process does not negatively alter the nutritional quality or safety of the food …” (Technical Summary at 3). Likewise, when it comes to the safety evaluation of genetically modified foods, Health Canada is to ensure it has been established “that the novel food is safe for consumption” (Food and Drug RegulationsB.28.002(1)).

Both Can Create New Toxic Substances

The process of irradiation when applied to beef can create new potentially toxic substances. The proposal to irradiate beef was first introduced in 1998, and Health Canada indicated in its 2002 initial evaluation that “[T]he main chemical change is the formation of small amounts of radiolytic products (RPs), some of which are volatile”.[iv] One is 2-ACB, and the Updated Evaluation states “an in vivo tumour promoter study, administering pure 2 ACBs, found an increase in tumour number and size, but not overall tumour incidence” (at 7).

The process of modifying the genes of foods can also create new potentially toxic substances. The explanation: “Genetic engineering introduces new genes, new genetic information, into the cells of a food producing organism. Since a gene is the blueprint for a protein, that new genetic information causes the organism to produce one or more new proteins. In turn, the food produced by that genetically engineered organism will contain those new proteins. Thus, genetic engineering introduces new ingredients, new constituents into foods….These new proteins could, themselves, cause allergies or be toxic. Alternatively, they could alter the cellular metabolism of the food-producing organism in unintended and unanticipated ways, and in turn, these alterations in metabolism could cause allergens or toxins to be produced in the food.”[v]

The record shows that genetic engineering can create toxic substances.[vi] One case in point is L- tryptophan, a food supplement, which was linked to the disease called eosinophilia-myalgia syndrome (EMS) that broke out in the late 1980s/early 1990s. Certain white blood cells that fight infection are called eosinopholis, and the levels associated with the disease were extremely high. The molecules that were supposed to attack invaders instead attacked the body’s normal tissue, causing pain at extreme levels. Symptoms included severe swelling of legs and arms, skin rashes, and breathing difficulties. At least 80 people died, 1,500 were permanently disabled and 5,000 to 10,000 were afflicted.

The particular strain of the supplement was derived from genetically altered bacteria, and it contained new and usual contaminants, at least one of which was highly toxic at low concentrations, and the concentrations of contaminants fluctuated over time; all of which point to genetic engineering. It has since been ascertained that one new contaminant that was created in the genetically engineered strain was “AAA”, which is fat soluble rather than water soluble. Unlike the other contaminants, it could lodge in fatty tissue and accumulate, likely resulting in triggering eosinophils and ultimately EMS.

The Public is Concerned with Both

Public concern with irradiated beef has historically been large. In fact, public concern was the reason that the initial proposal to irradiate beef was not approved by the government, although Health Canada had recommended it. The reason Health Canada cites is “The regulatory process to enable irradiation of ground beef was not completed due to the large number of questions received expressing concerns related to the safety of the food irradiation process in general.” (Technical Summary, at 3) It is well known from polls that a strong majority of Canadians want labels put on genetically modified foods.

So why will labels be put on irradiated beef, but not genetically modified foods? Perhaps the government acknowledges the public concern and risks associated with one but not the other.

]]>http://safefoodmatters.org/2016/08/31/a-beef-on-labeling-irradiated-meat-gets-a-label-but-gm-foods-do-not/feed/050Farm to Fork On Common Groundhttp://safefoodmatters.org/2016/07/22/farm-to-fork-on-common-ground/
http://safefoodmatters.org/2016/07/22/farm-to-fork-on-common-ground/#respondFri, 22 Jul 2016 18:12:17 +0000http://safefoodmatters.org/?p=24Sat. & Sun. September 24 & 25 noon to 6 #Farm2ForkTo #F2FOCG
Celebrate the harvest season and national Organic Week with a festival of healthy food, music, arts, and community. Featuring an organic farmers’ market, beer and wine, dozens of Non-GMO vendors, well-researched speakers, soulful music, collaborative art making for all ages, environmental defenders, and food safety and seed freedom educators.www.toronto.ca/forteventshttp://nongmo.to/
]]>http://safefoodmatters.org/2016/07/22/farm-to-fork-on-common-ground/feed/024TO THE SALMON CONSUMER: I’M NOT BUYING IT.http://safefoodmatters.org/2016/07/22/to-the-salmon-consumer-im-not-buying-it/
http://safefoodmatters.org/2016/07/22/to-the-salmon-consumer-im-not-buying-it/#respondFri, 22 Jul 2016 17:33:07 +0000http://safefoodmatters.org/?p=18Salmon that has been genetically modified to grow faster has been approved. Health Canada states “in every other way, the AquaAdvantage salmon is identical to other farmed salmon”. Not true. For one thing, it has higher levels of the growth hormone IGF-1[i][ii], which is tied to several common cancers, including prostate, breast, colorectum, and lung[iii]. For another, some of the GM salmon show a statistically significant increase (1.5 fold) in allergen content. Lastly, the eggs are pressure shocked to produce an abnormality so that they aren’t fertile.

I’m not eating that fish. Would you eat that fish?

And these three points on GM salmon are set out in Health Canada’s own document[iv]. So how can Health Canada approve the fish? Simple: it is silent on these points or it accepts the explanations presented by AquaBounty that the points aren’t “relevant”:

On the finding of higher levels of IGF-1, Health Canada accepts this is “not toxicologically relevant since a daily serving of AAS containing the highest potential level of IGF-1 … would not exceed the levels of IGF-1 present in a daily serving of milk and will have negligible health effects on the most sensitive subpopulation (teenage boys).”

On the finding of allerginicity, Health Canada accepts the opinions of experts provided by AquaBounty that “the elevation in allergen content in diploid AquaAdvantage Salmon is unlikely to be relevant in terms of a biological/clinical response and that this elevation would not exceed the variation that might occur when a consumer eats a small or a large portion of food”.

It doesn’t speak to the shocking of the eggs.

But the mandate of Health Canada is “the protection of the people of Canada against risks to health” (Department of Health Act). When it comes to GM salmon, it was supposed to review the information provided by AquaBounty to see if it “establishes that the novel food is safe for consumption” (Food and Drug RegulationsB.28.002(1)). And the Trudeau government promised it would ensure that “scientific analyses are considered when the government makes decisions”.

The evidence on GM salmon showed concerns about toxicity and allerginicity, but it was approved anyways. If the government wants to live up to its promise and its mandate on GM foods, it needs to be convinced that science establishes the food is safe for consumption. Not explain away the concerns as not relevant. I’m not buying it.